, PLEASE USE THIS DOCUMENT AS A GUIDE ONLY
Unpacking Assumptions, Power, and Audience Agency: A Decolonial Analysis of the BCCSA
Free-to-Air Code of Conduct for Broadcasting Services Licensees (2009)
1. INTRODUCTION
Communication policy is not a neutral or technical instrument. It is a site of struggle, negotiation,
and often, the quiet reproduction of historical inequalities. In South Africa, broadcasting regulation
emerges from a complex interplay of technological change, economic globalisation, and the enduring
legacies of colonialism and apartheid. These forces raise fundamental questions about whether
contemporary communication policies genuinely serve African audiences or whether they merely
repackage old power structures in new institutional forms. This essay undertakes a decolonial policy
analysis of the Broadcasting Complaints Commission of South Africa (BCCSA) Free-to-Air Code of
Conduct for Broadcasting Services Licensees (2009) to interrogate precisely these questions.
Scholars such as Grosfoguel (2007) have argued that coloniality does not end with formal
independence. Instead, it persists in knowledge systems, institutional frameworks, and the very
assumptions that underpin policy. Similarly, Napoli (2007) emphasises that policy decisions directly
shape audience experiences, access, and the broader communicative environment. To examine
broadcasting policy critically, therefore, requires more than a surface-level evaluation of its rules. It
requires a deep interrogation of whose knowledge counts, whose voice is centred, and which
audiences are imagined as active participants versus passive recipients.
The BCCSA Free-to-Air Code of Conduct (2009) was selected for this analysis because it governs
the everyday communicative relationships between broadcasters and audiences in South Africa. It
addresses issues of hate speech, dignity, representation, children’s programming, and news
impartiality. As such, it is a critical site for examining how broadcasting regulation addresses—or
fails to address—the needs of diverse, multilingual, and historically marginalised audiences. This
essay approaches the Code from a decolonial and audience-centred perspective, interrogating three
interconnected domains: the policy’s underlying assumptions, the power dynamics shaping its
implementation, and the extent to which it foregrounds audience agency.
Scholars such as Alasuutari (2014) highlight the role of epistemic governance in shaping
communication environments, noting that how a policy defines a problem determines what solutions
become visible. Meanwhile, Milton and Mano (2022) introduce the concept of Afroloquy to
emphasise African voices, ontologies, and perspectives in media discourse. This essay draws on
these frameworks to argue that while the BCCSA Code contains progressive elements, its
foundational assumptions remain shaped by Eurocentric legalism, individualised complaints
procedures, and a limited conception of audience agency. Without deliberate decolonial reform, such
policies risk perpetuating epistemic exclusion even as they claim to protect dignity and
representation.
Unpacking Assumptions, Power, and Audience Agency: A Decolonial Analysis of the BCCSA
Free-to-Air Code of Conduct for Broadcasting Services Licensees (2009)
1. INTRODUCTION
Communication policy is not a neutral or technical instrument. It is a site of struggle, negotiation,
and often, the quiet reproduction of historical inequalities. In South Africa, broadcasting regulation
emerges from a complex interplay of technological change, economic globalisation, and the enduring
legacies of colonialism and apartheid. These forces raise fundamental questions about whether
contemporary communication policies genuinely serve African audiences or whether they merely
repackage old power structures in new institutional forms. This essay undertakes a decolonial policy
analysis of the Broadcasting Complaints Commission of South Africa (BCCSA) Free-to-Air Code of
Conduct for Broadcasting Services Licensees (2009) to interrogate precisely these questions.
Scholars such as Grosfoguel (2007) have argued that coloniality does not end with formal
independence. Instead, it persists in knowledge systems, institutional frameworks, and the very
assumptions that underpin policy. Similarly, Napoli (2007) emphasises that policy decisions directly
shape audience experiences, access, and the broader communicative environment. To examine
broadcasting policy critically, therefore, requires more than a surface-level evaluation of its rules. It
requires a deep interrogation of whose knowledge counts, whose voice is centred, and which
audiences are imagined as active participants versus passive recipients.
The BCCSA Free-to-Air Code of Conduct (2009) was selected for this analysis because it governs
the everyday communicative relationships between broadcasters and audiences in South Africa. It
addresses issues of hate speech, dignity, representation, children’s programming, and news
impartiality. As such, it is a critical site for examining how broadcasting regulation addresses—or
fails to address—the needs of diverse, multilingual, and historically marginalised audiences. This
essay approaches the Code from a decolonial and audience-centred perspective, interrogating three
interconnected domains: the policy’s underlying assumptions, the power dynamics shaping its
implementation, and the extent to which it foregrounds audience agency.
Scholars such as Alasuutari (2014) highlight the role of epistemic governance in shaping
communication environments, noting that how a policy defines a problem determines what solutions
become visible. Meanwhile, Milton and Mano (2022) introduce the concept of Afroloquy to
emphasise African voices, ontologies, and perspectives in media discourse. This essay draws on
these frameworks to argue that while the BCCSA Code contains progressive elements, its
foundational assumptions remain shaped by Eurocentric legalism, individualised complaints
procedures, and a limited conception of audience agency. Without deliberate decolonial reform, such
policies risk perpetuating epistemic exclusion even as they claim to protect dignity and
representation.
